Blog: Regulation

The FDIC Board of Directors just concluded their special meeting to discuss the Special Assessment Final Rule.  The FDIC Board elected to change the following:[more]

  1. Reduce the rate used to calculate the special assessment;
  2. Change the base used to calculate the special assessment;
  3. Cap the amount of the special assessment
  4. Reduce the rate used to calculate any additional special assessment or assessments that become necessary;
  5. Change the base used to calculate any additional special assessments or assessments that become necessary;
  6. Cap the amount of any such additional special assessment; and,
  7. Terminate authority to impose any additional special assessment under this Final Rule on January 1, 2010.

This reduce the initial proposed assessment of 20 points (.20/per $100 of insured domestic deposits) to .05bp of total assets minus capital.  This change is substantial for community banks, since now the majority of the recapitalization will be placed on larger regional and national megabanks.

To read the final rule, visit


On March 4, 2008, the Securities and Exchange Commission proposed amendements to Regulation S-P: Privacy of Consumer Financial Inforamtion and Safeguarding Personal Information, which implements certain provisions of the Gramm-Leach-Bliley Act (GLBA) and the Fair Credit Reporting Act (FCRA) for entities regulated by the Commission.  Comments were accepted through May 12th.  To read the proposal visit



The Department of the Treasury recently published Interagency Guidance on Response Programs for Unauthorized Access to Customer Information and Customer Notice.

You are probably familiar with the publication of this guidance as described by The Federal Reserve Board at

The Text of Common Final Guidance contains Supplement A to Appendix B which is being incorporated into agency regulations. It would be wise for appropriate bank personnel to be familiar with this supplement’s text (found on page 32 of attachment found at The entire document is useful in understanding the overall guidance and thought processes behind the rulings, but the actual guidance text begins on page 32. [more]

The CoNetrix Security Group has reviewed the guidelines and has drafted recommended updates to Information Technology Security Policies. Within the next few weeks, we will contact the banks with which we have worked on such policies. If you have not worked with CoNetrix regarding preparation of security policies and are interested in doing so, please contact us.